Notice 2022-21, 2022-2023 Priority Guidance Plan Submission

132 Pages Posted: 9 Jun 2022

See all articles by Jeffery M. Kadet

Jeffery M. Kadet

University of Washington - School of Law

Date Written: May 26, 2022


This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.

Much of the submission concerns sourcing and effectively connected income rules. It also covers the existence of unanticipated partnerships among an MNC's group members that conduct joint business activities. Regarding subpart F, it makes suggestions concerning the manufacturing branch rule. Finally, it includes suggestions regarding the manner in which tax treaties should or should not apply to certain hybrid entities and how cost sharing agreements should be administered under Rev Proc 2015-41.

Keywords: ECI, Effectively Connected Income, Tax Treaties, Source of Income, Transfer Pricing, §482, Partnership, Check-the-Box, Entity Classification Rules, Subpart F, Branch Rule, CSA, cost sharing agreement, section 482

JEL Classification: H21, H25, K34, E62

Suggested Citation

Kadet, Jeffery M., Notice 2022-21, 2022-2023 Priority Guidance Plan Submission (May 26, 2022). Available at SSRN: or

Jeffery M. Kadet (Contact Author)

University of Washington - School of Law ( email )

William H. Gates Hall
Box 353020
Seattle, WA 98105-3020
United States

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